CONTRACTOR SAFETY PROGRAM
WISCONSIN PAPER COUNCIL
The OSHA 10+ Contractor Safety Program is a voluntary, cooperative
initiative involving the Wisconsin Paper Council’s member firms, plus
dedicated construction associations, contractors, employees in the
construction and related trades, the Occupational Safety & Health
Administration (OSHA) and the Wisconsin Safety Consultation
The participation of these interests emphasizes their shared objective:
a safe job site for all workers.
It is important to acknowledge that any success that this initiative may
realize will be possible only because of the long-term and continuing
commitment to safety demonstrated by all involved.
Without their decades of safety achievements this initiative would not
These interests are committed to assuring work sites where the rules
and regulations of the Occupational Safety & Health Administration
(OSHA) are minimum standards, rigorously applied and followed, and
where safety best management practices go beyond compliance (see:
29 CFR Part 1910, General Industry, and CFR Part 1926,
IF YOU HAVE QUESTIONS ABOUT THIS PROGRAM, PLEASE CONTACT:
Contractor Safety Coordinator
Wisconsin Paper Council
P.O. Box 718
250 North Green Bay Road (zip: 54956)
Neenah, WI 54957-0718
TABLE OF CONTENTS
Safety Topics Page Number
Blood-Borne Pathogens 1
Confined Space Entry 2
Electrical Safety 8
Excavations & Trenching 11
Fall Protection 13
Fire Protection & Hotwork 15
Hazard Communication (HazCom) 17
Lockout / Tagout 21
Material Handling, Hoists & Rigging 24
Motor Vehicles & Motorized Equipment 26
Personal Protective Equipment (PPE) 27
Powered Industrial Trucks 30
Process Safety Management (PSM) 31
Scaffolds, Lifts, Ladders & Stairways 34
Signs, Signals & Barricades 37
Site-Specific Safety Orientation 39
Tools – Hand & Power 42
Walking & Working Surfaces 45
Safety Policies Page Number
Safety Best Management Practices 47
Code of Conduct 51
This document’s format is uniform. For each of the safety topics following the
title header, there is a brief Introduction.
It is followed by a list of several Keys identifying focal areas for each topic.
The bulk of each topic is comprised of further Discussion (text, bullet points)
describing awareness level expectations.
The discussion sections are based on outlines developed with the advice and
guidance of several dozen volunteer safety professionals representing OSHA,
trade organizations, contractors and contractor associations and paper
Without their assistance and expertise this project would not have been possible.
Their commitment to safe work places is sincerely appreciated.
Accidents can occur at worksites. Accidents create a risk for exposure to blood-
borne pathogens, including, but not limited to, hepatitis (non-A, non-B) and
human immunodefiency virus (HIV or AIDs). Contractor employees need to be
aware of basic practices and equipment that can limit their exposure risk.
Keys to Blood-Borne Pathogens
• Personal Protective Equipment (PPE).
• Required for training.
• Safe response practices.
• Response to exposure.
Personal Protective Equipment (PPE)
Contractor employees responding to an accident will be aware of the need to
keep a clear mind and avoid irrational impulses or actions. They will be aware
that universal practices call for the use of first aid kits and appropriate PPE,
including gloves, protective eyewear and use of a one-way ventilation device or
rescue bag. Contractor employees will understand the need for PPE to be free
of defects, correctly fit the individual, and be appropriate to the task.
Required for Training
Contractor employees will be aware that they require specialized training before
responding to situations presenting a risk of blood-borne pathogens.
Contractor employees will be aware that instruction that enables individuals to
respond to the risk of blood-borne pathogens includes:
• Use of disposable gloves and other necessary personal protective equipment.
• Covering fluids with a paper towel, cloth or other absorbent materials,
allowing fluids to be absorbed.
• Cleaning the exposed area with disinfectant.
• Removing all PPE, except disposable gloves, and depositing them in a
medical hazard waste bag or container.
• Removing disposable gloves by turning them inside out and depositing them
in the medical hazard waste bag or container.
• Securing the disposable bag or container and disposing of it in a “hazard
• Cleaning hands with disinfectant.
Contractor employees will be aware of the importance of maintaining a clean
working environment, including the safe disposal of any potentially contaminated
PPE or equipment.
Response to Exposure
Contractor employees will be aware of the appropriate responses if they or a co-
worker have been exposed to blood-borne pathogens.
CONFINED SPACE ENTRY
A confined space, generally speaking, is one in which an individual’s ability to
move about or exit is limited or restricted. Potential risks include oxygen
deficiency, toxic atmosphere, entrapment, engulfment, fire or other physical
danger. Some confined spaces are obvious, but others may not be apparent. It
is important for all construction workers to be aware of what confined spaces are
and the potential hazards they represent. It is imperative that contractor
employees are aware that only those individuals having received specialized
training are permitted to enter a confined space regardless of circumstances.
Keys to Confined Space Entry
• Definitions of “confined space” and “permit-required confined space.”
• Entry procedures; individuals who may enter a confined space or be involved
in a confined space entry.
• Roles and responsibilities of supervisors, attendants and entrants.
Confined Space/Permit Required Confined Space
Contractor employees will know the definitions of a confined space and a permit-
required confined space.
Confined Space – A confined space is one that:
• Is large enough to enter.
• Has limited or restricted means of entry or exit.
• Is not designed for continuous occupancy.
Some paper industry examples include:
• Boilers • Chests • Tunnels
• Diked Areas • Dryer Cans • Digesters
• Manholes • Open-Top Spaces - • Excavations
• Pits 4’ deep or greater • Silos
• Storage Bins • Process Vessels • Tank Cars
• Trenches • Tanks
Permit-Required Confined Space - Contractor employees will know that a
permit-required confined space meets all of the three criteria of a confined
space (above) and any of the following:
• Contains, or has potential to contain, hazardous atmosphere.
• Contains a material with the potential for engulfing an entrant.
• Has an internal configuration that may cause an entrant to be trapped or
• Contains any other recognized serious safety or health hazard, such as
risk of falling or tripping, excessive noise, risk of burns or mechanical
Contractor employees will know that personnel not authorized by permit are
forbidden from entering a permit-required space.
Types of Confined Space Hazards
Contractor employees will be aware of the potential dangers of confined space
Atmosphere - Hazards include gases, vapors, airborne dust, and oxygen
enrichment and oxygen depletion. Atmospheric hazards can suffocate or
poison an entrant, explode, or feed a fire.
Energy Sources - Energy sources are those with the potential to release
electrical or stored energy if not properly controlled or deactivated.
Hot Work - Hot work includes welding and cutting, burning and heating,
and riveting. All can create sparks, flame or heat sufficient to ignite
flammable materials in a confined space causing an explosion and/or fire.
Entrapment - Entrapment occurs if the shape, size or other attribute of a
confined space slows or halts exit.
Special Considerations - Confined spaces must be assessed for the
presence of special health risks including, but not limited to arsenic,
asbestos, lead, silica or radiation.
Sewer Entry - Entry into a sewer system is an example of a specific
Engulfment - Engulfment describes an entrant becoming trapped or
enveloped inside a confined space by a liquid or a “flowable” solid (some
paper industry examples include wood chips, starch or pelletized
Radiation - Confined spaces must be tested and monitored to assure they
do not present a risk of radiation exposure.
Site Specific - Contractor employees will be aware that different work
sites present the potential for different hazards and safety
rules/procedures. They will be aware that personnel involved in a
confined space entry will receive site-specific information/training prior to
Confined Space Entry Procedures
Contractor employees will be aware that there are specific procedures required
before and during safe operations in a permit-required confined space. They
Cleaning, Purging, Flushing or Ventilation - Many confined spaces
need specific treatment – such as cleaning, purging, inerting (i.e., making
the atmosphere non-flammable, non-explosive and non-reactive), flushing,
ventilating – by trained individuals before and/or during a safe entry.
Isolation of Energy (Lockout, Blanking, Blocking & Bleeds) -
Equipment in a confined space must be in a “zero energy state” by trained
personnel to prevent unexpected activation or release of energy.
Testing for Specific Atmospheric Hazards - Prior to entry, the
atmosphere in a confined space must be tested at all elevations or levels,
and in all areas, by trained personnel using calibrated equipment. The
atmosphere must be continuously monitored, or retested periodically, as
long as the space is occupied. The atmosphere should be tested for its
oxygen content first.
Sampling of Special Situations - Confined spaces need to be sampled
to assure they do not pose a risk for exposure to various substances,
including but not limited to arsenic, asbestos, lead, silica or radiation.
Electrical Protection (Low Voltage/GFCI) - Electric-powered tools and
lighting used in confined spaces must be low voltage and connected to a
ground fault circuit interrupter.
Prevention of Unauthorized Entry - Individuals who are not authorized
must never enter a permit-required confined space. Appropriate
measures will be taken by employers to preclude unauthorized entry.
Protective Barriers/Warnings - Confined spaces must be adequately
barricaded and clearly identified with signage and/or other devices that
warn of the potential danger.
Personal Protective Equipment for Confined Space - Safe entry into a
confined space may require the use of specialized personal protective
equipment, such as safety harnesses and life lines, extrication devices,
respirators and related gear. PPE selection is specific to the confined
space and is the responsibility of a trained individual.
Multi-Contractor/Sub-Contractor Work Site Coordination - When more
than one contractor or sub-contractor is active at a work site,
communication must be coordinated to assure all appropriate personnel
are aware of confined space dangers.
Responsibilities and Duties of Supervisors, Attendants, Entrants
Contractor employees will understand that safe entry into a permit-required
confined space requires the existence of a detailed, printed plan developed by
the employer; the issuance of an approved permit; and establishing employee
proficiency in the duties and roles required, as indicated:
Supervisor - The supervisor is responsible for assuring safe conditions
before and during the entry.
The supervisor knows the hazards the space presents, assures that safe
entry conditions exist, terminates an entry when unsafe conditions are
detected, assures that rescue services are available, stops unauthorized
individuals from entering the space and removes unauthorized individuals
who enter the space. The supervisor may also serve simultaneously as
the attendant. When doing so, the supervisor assumes the responsibilities
for both roles.
Attendants - Attendants are responsible for continuously monitoring the
entry and supporting the entrant.
Attendants know the hazards the space presents, know the possible
behavioral effects of the hazards on entrants, maintain a continuous count
of the entrants, communicate with entrants to monitor their status,
terminate an entry when unsafe conditions are detected. Attendants also
know how to communicate with the rescue service, perform non-entry
rescues, stop unauthorized individuals from entering the space and
remove unauthorized individuals who enter the space, assist the
supervisor, and remain at the confined space until relieved.
Entrants - Entrants are individuals that have received specialized training,
are authorized by permit to enter the space, perform identified tasks under
specified conditions during a limited and defined time period.
Entrants know the hazards the space presents comply with all entry rules,
communicate with attendants, and immediately alert attendants and other
entrants to any warning sign of an unsafe entry.
Rescue – Contractor employees will understand the need to plan ahead should a
rescue be necessary.
For example, the entry permit must identify the rescue service to be contacted
and how to contact it, plus any rescue equipment to be available at the entry site.
Additionally, contractor employees will understand that individuals assigned to a
rescue team will have received specialized training prior to being involved in a
rescue, and will have practiced rescues.
Contractor employees will be aware that demolition is a highly specialized activity
that requires thorough planning and competent supervision to be performed
safely. They will further understand that demolition includes remodeling and
Keys to Demolition
• Engineering survey.
• Safe Practices.
Contractor employees will be aware that prior to starting a demolition project, a
“competent person” must have performed an engineering survey to determine
the condition of the framing, flooring, walls, and the potential for an unplanned
collapse of any portion of the structure or object. Any adjacent structure where
paper or contractor employees may be exposed must also be similarly checked.
Contractor employees will be aware that demolition activities may be performed
only under competent supervision. Demolition projects require a written plan
identifying the safe work practices to be followed.
Additionally, contractor employees will be aware of general safe practices
required by law, including:
• The demolition area must be barricaded to prevent unauthorized persons to
enter or move within.
• All electric, gas, water, steam, sewer and other service lines shall be shut off,
capped or otherwise controlled outside the building line before demolition
work commences. Any public or private utility that is involved must be notified
• If it is necessary to maintain any utilities during demolition, they must be
relocated and protected.
• If also must be determined if any hazardous chemicals, gases, explosives,
flammable materials or other dangerous substances have been used in any
pipes, tanks or other equipment on the property. If their presence is apparent
or suspected, testing and purging must be performed and the hazard
eliminated before demolition commences.
• If a structure to be demolished has been damaged by fire, explosion or other
catastrophe, the walls and floor must be shored or braced.
• Contractor employees may not work below other employees during demolition
• If a hazard exists for contractor or paper employees falling through a wall
opening, it must be protected to a height of approximately 42 inches.
• Related hazards, such as the risk of fragmented or broken glass, must be
removed or eliminated.
• Unstable structures must never be left in-place without temporary support.
• Waste materials generally should not be dropped or thrown to the ground.
They must be lowered through the use of cranes or chutes. If use of a chute
is not possible, the area in which debris is dropped must be completely
enclosed (barricades at least 42 inches high and 6 feet back from the
projected edge of the opening above). Signs warning of the hazard of falling
materials must be posted at each level.
• All floor openings must be covered with material substantial enough to
support any load placed upon it.
• Employee entrances to multi-story structures being demolished must be
completely protected by sidewalk sheds and/or canopies providing protection
from the face of the building for a minimum of 8 feet.
• Any asbestos-containing materials must be removed according to local, state
and federal regulations.
• Crane operators involved in demolition work must be able to see the work, or
a signal person must be utilized to direct the crane operator.
Unsafe electrical practices pose numerous risks to workers, including shocks,
burns and fire, and electrocution. Electrical safety awareness provides workers
with the knowledge, skills and tools to avoid these risks, whether their potential
exposure is direct, indirect or incidental to their assignment.
Keys to Electrical Safety
• Potential hazards.
• Qualified people.
• “Diggers” Hotlines (utility or municipal).
Keys to Electrical Safety, continued
• Assured equipment ground program.
• Ground Fault Circuit Interrupters (GFCI).
• Related safety practices and procedures.
Awareness will include an understanding of the potential harmful effects of
• Burns • Explosions
• Fire • Shocks
Contractor workers will understand that a range of hazards is possible. Some of
the most likely include temporary electrical set-ups, frayed or worn extension or
power cords, and exposed junction boxes.
Awareness will include an understanding of important terms and concepts,
• Circuits (faulted, short) • Electrical Isolation
• Energized parts or equipment • Ground fault
• Grounding • Insulators
• Interruption • Ohm’s Law
• Wiring (permanent, temporary) • Resistance
Contractor employees will be aware that only qualified people can work with
exposed live conductors and electrical parts. Qualified people are those
individuals who have the necessary training to avoid the electrical hazards of
working on or near exposed energized parts.
Contractor employees will be aware of the need to contact appropriate utility
services – such as public or private utilities’ “digger hotlines” – or the owner’s
representative to identify precisely locations of underground utilities and related
information prior to starting work.
Assured Equipment Ground Program
Contractor employees will understand what an Assured Equipment Grounding
Program is, including its capabilities and limitations, and its key aspects
• Requirement for written programs.
• Role of competent person(s).
• Inspections and testing.
Ground Fault Circuit Interrupter (GFCI)
Contractor employees will be aware of the use of Ground Fault Circuit
Interrupters (GFCI) in electric safety, including:
• Capabilities and limitations.
• Who uses GFCI’s.
• When GFCI’s are used.
Related Safety Practices
Contractor employees will be aware of important related practices that help
assure electrical safety, including:
Electric Line Awareness - Contractor employees will understand safety
practices needed when working around overhead, buried or concealed
electric lines. Awareness will include an understanding of working
clearances around energized lines and safety practices related to
conductive equipment (e.g., back hoes, cranes, aerial lifts) and platforms
Flexible/Extension Cords - Contractor employees will be aware of
flexible cord set safety practices, including how to use cords,
misuse/abuse to avoid, maintenance and the need to tag defective cords
and tools as “Do Not Use” and to remove them from service.
Lockout/Tagout - Contractor employees will be aware of the importance
and function of lockout / tagout programs in electric safety. They will be
aware that only qualified people (see below) may work with exposed live
conductors and electrical parts. They will also be aware of the importance
of safe procedures, including circuit tests that are followed whenever
equipment is deenergized and reenergized.
Conductive Materials - Contractor employees will have an awareness of
the safe use of conductive materials, such as duct tape.
Personal Protection Equipment - Contractor employees will be aware
that certain PPE is necessary to assure electrical safety, including (but not
• Eye/face protection.
• Insulated tools for qualified personnel.
• Non-conductive headwear.
• Task-specific or specialized PPE.
• Testing of PPE and tools.
EXCAVATIONS & TRENCHING
Excavations and trenches present a number of serious hazards regardless of the
job site. Awareness and application of safety practices reduce the potential risks
presented by unsafe work habits, changes in soil stability and vibrations in the
Keys to Excavations & Trenching
• Excavation types.
• Safety practices prior to starting work.
• Competent and qualified person.
• Emergency response/equipment team.
• Sloping and protective systems.
Contractor employees will understand what constitutes and how to recognize an
excavation (operations at a depth of 4 feet deep or greater) and related activities,
• Cavities • Depressions
• Man-Made Cuts • Shielding
• Sloping • Trenches
Contractor employees will understand that an exit, or safe means of escape,
must be available within 25 feet of any worker in excavations that are 4 feet or
more deep. For example, a ladder used for exit purposes must not be outside of
the trench box.
Additionally, protective systems are needed in any excavation that is 5 feet or
deeper, and may be required in excavations that are less than 5 feet deep under
Contractor employees will have an awareness of related safety provisions,
including the use of sloping (inclination of side walls) to protect workers, the need
to avoid exposure to falling loads, and the importance and use of warning
systems on mobile equipment adjacent to excavations.
Contractor employees will understand the potential dangers related to each type
and the rules, procedures and equipment used to eliminate or control the
dangers. Contractor employees also will understand the risks posed by
underground utilities and the steps necessary to eliminate or control the risk.
Safety Practices Prior to Starting Work
Contractor employees will be aware of the steps that must be undertaken and
permit(s) required prior to beginning excavation, trenching and shoring activity.
Competent and Qualified Person
Contractor employees will understand the roles of the “competent person” and
the “qualified person” (registered professional engineer) – individuals trained to
address the specifics of excavating, trenching and shoring activities and safety
practices, including soil classification and the use of protective systems.
Definitions - OSHA defines a competent person as “…one who is
capable of identifying existing and predictable hazards…who has
authorization to take prompt, corrective measures to eliminate them.”
OSHA defines a qualified person as one who “…has knowledge, skills,
experience, training, certification or professional standing to solve or
resolve problems related to the subject matter, the work or the project.”
These are important terms as they are referenced in all OSHA regulations.
Protective systems include: (a) side supports for excavations or shoring, (b)
shields, and (c) sloping or benching of the sides of excavations.
Individuals will be aware of the types of soil classifications ( A, B, C and rock),
the role of the competent person in performing soil type analysis, and the
potential dangers presented by various soil types.
Emergency Response/Equipment Team
Contractor employees will be aware of the importance and role of emergency
response equipment/teams related to excavations, trenching and shoring,
including the need to develop an advance plan that addresses:
• Who is responsible for calling for rescue, fire or other professional help?
• Who is responsible for initial rescue and aid efforts?
• What rescue and emergency equipment is available on the job site, where it
is located, who is qualified to use it?
• Who is responsible for directing rescue, fire and other professional help to the
Introduction to Fall Protection
OSHA reports that more than 100,000 job site falls occur annually. Most fall
injuries (85%) result in lost time. Falls account for 11% to 12% of all fatal work
injuries in the United States. Most common are falls from roofs, scaffolds and
ladders, open-sided floors and work platforms, hole openings in floors, falls
associated with the use of aerial lifts, and falls occurring when working above
machinery or other hazards.
But all falls are potentially serious. A safe workplace also protects workers from
Keys to Fall Protection
• Recognizing fall hazards.
• Fall protection devices and selection.
• Personal fall arrest systems.
• Anchorage points.
• Maintenance, cleaning and storage.
Fall Protection Devices and Selection
Contractor employees will be aware of the potential dangers and causes of falls
and the rules, procedures and tools used to eliminate or control the dangers.
Contractor employees will understand the types of equipment and devices used
to prevent and arrest falls (separately and in combination), and when fall
protection is required, including requirements related to height and elevated work
for these devices:
• Personal fall arrest systems (see below), plus:
q Controlled access zones
q Hole covers
q Positioning device systems
q Safety monitoring systems
q Safety net systems
q Warning line systems
Contractor employees will be aware that employers must provide and install all
required fall and falling object protection devices prior to the commencement of
work. The equipment must include anchoring devices selected by a competent
Contractor employees must be aware that employers must create a rescue plan
for workers who are in an arrested condition.
Employers also must provide training, with a competent person as the instructor,
whenever workers may be exposed to fall hazards.
Personal Fall Arrest Systems
Contractor employees will be aware of personal fall arrest systems, including
their components such as the body harness, lines, connecting devices and
anchor, and may include, as necessary, a lifeline, a deceleration device, or both.
Contractor employees will understand that personal fall arrest systems must be
rigged so that the wearer can not fall more than 6 feet and can not come into
contact with any lower level. They will understand that the device must bring an
individual to a complete stop and limit maximum deceleration traveled to 3.5 feet.
Contractor workers will be aware of the components of a body harness and their
proper use, including:
• Shoulder straps and retainer
• Waist straps
• Thigh straps
• Sub-pelvic support
• Adjustment buckles
Contractor employees will be aware of the importance of proper anchorage (the
secure point of attachment for equipment such as lifelines, lanyards and
They will understand that fall arrest systems must limit the maximum arresting
force on the employee to 1,800 pounds and that anchorage points must be
capable of supporting at least 5,000 pounds per attached employee.
Contractor employees will be aware that anchorage must be independent of any
other anchorage in use to support or suspend platforms, and that personal fall
arrest systems must not be attached to guardrails.
Maintenance, Cleaning and Storage
Contractor employees will understand the importance of proper maintenance,
inspection, cleaning and storage of fall protection devices and equipment.
Contractor workers will be aware of the need to replace equipment after a fall.
FIRE PREVENTION & HOTWORK
Fire and explosions are a serious threat to life and property in all aspects of our
daily lives. Fires and explosions in the workplace are estimated by OSHA to be
responsible for well over $2 billion in damages, plus the death of several hundred
Hotwork – welding, cutting, brazing, soldering and related activities – presents a
unique risk for fire and explosions to welders, their assistants, and others in the
vicinity. Hotwork also requires eye protection for those involved and the need for
caution by others in the vicinity.
It is often said that the best protection from fire is to avoid starting one.
Contractor employees will be aware of fire hazards – including the use of
cigarettes and other tobacco products – and those presented by hotwork, plus
the rules, procedures and equipment used to eliminate or control the dangers.
Keys to Fire Prevention & Hotwork
• Combustion and fire components.
• Fire extinguishers.
• Paper industry specific fire hazards.
• Flammable and combustible liquids and gases.
• Hot work precautions.
• Potential ignition sources.
Combustion and Fire Components
Contractor employees will understand the importance of preventing fires and the
basic elements or components of combustion and fire. Awareness will include an
understanding of the four components of fire in the context of fire prevention and
• Chemical reaction
Contractor employees will understand the basic types of fires, including:
• Class A: paper, plastics, rubber, wood.
• Class B: liquids, gases, grease.
• Class C: electrical, including circuit breakers, fuse boxes, electrical
• Class D: metals.
Contractor workers will know the types, location and proper operation of fire
extinguishers used for each.
Paper Industry Specific Fire Hazards.
Contractor employees will be aware of specific fire hazards common to the pulp
and paper industry, including:
• Noncombustible gases (NCG) • Paper dust
• Roll & broke paper storage areas • Sawdust
• Turpentine • Waste paper
Contractor employees will be aware of the procedures and equipment used to
eliminate or control the hazards.
Hot Work Precautions
Contractor employees will understand the intent and purpose of permit
requirements, the proper use of shields, and the precautions necessary around
various categories of hotwork, including:
• Cutting • Brazing
• Burning • Grinding (spark-causing activities)
• Soldering • Welding
Contractor employees will understand fire watch procedures, when they are
implemented, and the need for eye protection.
Flammable & Combustible Liquids & Gases
Contractor employees will be aware of specific procedures and equipment
necessary for the safe handling and storage of flammable and combustible
liquids and gases, including those presented by compressed gas cylinders and
welding gas cylinders and carts.
Potential Ignition Sources
Contractor employees will be aware of potential ignition sources, such as welding
and cutting operations, lighting systems and temporary heaters during cold
Additionally, they will be aware that smoking is prohibited by OSHA regulations at
or in the vicinity of operations that are a fire hazard. Such operations will be
conspicuously posted with signs indicating: NO SMOKING OR OPEN FLAME
HAZARD COMMUNICATION (HazCom)
OSHA estimates that approximately 25% of the workforce handles, or is in the
vicinity of, hazardous chemicals on a daily basis. All workers will understand
they have a right to know what chemicals they may be exposed to and will know
how to protect themselves from potential hazards.
Keys to Hazard Communication
• Types of hazards.
• HazCom rights and obligations.
• Material Safety Data Sheets (MSDS).
• Written HazCom program.
• Paper industry specific chemicals/processes.
• Substances requiring specific training.
• Related safety topics and practices.
• Labeling requirements.
Types of Hazards
Contractor employees will be aware of the two basic types of hazards – health
and physical – and the categories of each:
Health Hazards – includes exposure to chemicals that may cause acute
or chronic impacts to human health. Contractor employees will be aware
of the types of substances that can cause acute or chronic health impacts,
• Carcinogens • Organ-specific reactors (sulfuric acid, asbestos)
• Corrosives • Sensitizers
• Irritants • CNS (Central nervous system disorders)
Physical Hazards – includes the following categories:
• Compressed gases. • Pyrophoric substances
• Explosives. (spontaneously ignitable in air at or
• Flammable liquids or solids. less than 130° Fahrenheit).
• Flammable liquids or solids. • Unstable materials.
• Organic peroxides. • Water-reactive materials.
HazCom Rights and Obligations
Contractor employees will be aware of their rights and obligations relating to
federal and state regulations, including access to information and training
regarding all hazardous chemicals with which they work or are exposed, how to
protect themselves and their employer’s training requirements, including:
• Determining hazards of chemicals.
• Availability of a written hazard communication program.
• Availability of material safety data sheets.
• Requirements regarding hazard training and information, including:
q How to detect the presence of hazardous chemicals in the workplace.
q Health and physical hazards of chemicals in the workplace.
q How to protect against chemical hazards.
q Information on the employer’s hazard communication program.
Material Safety Data Sheets (MSDS)
Contractor employees will be familiar with material safety data sheets, including
their basic information, why they are required, information provided and related
key aspects, including:
• Employee and employer responsibilities.
• What are material safety data sheets.
• How to access MSDS.
• How to read MSDS, including common terms.
• The importance of information sharing in workplaces with multiple
contractors / sub-contractors.
Contractor employees will be aware of basic information provided in material
safety data sheets, including:
• Identity of the chemical.
• Physical and chemical characteristics.
• Health and physical hazards.
• Routes of entry into the body.
• Exposure limits used (PELs, TLVs) or recommended by the MSDS preparer.
• Precautions that allow safe handling and use.
• Control measures.
• Emergency and first aid procedures (also see below).
• Manufacturer’s name and contact information.
• Date latest revision was prepared.
Written Haz/Com Program
Contractor employees will be aware that a written hazardous communication
program must be available and what information it must contain, including:
• List of all hazardous chemicals present in the workplace.
• How MSDS requirements are satisfied.
• The type of labeling system in use.
• How workers will be informed of “non-routine” hazards.
They also will be aware that training must be provided – initially and whenever a
new hazard is introduced into the workplace – to assure a safe working
Paper Industry Specific Chemicals / Processes
Contractor employees will be aware of the potential hazards presented by
chemicals commonly used in paper installations and how to protect themselves.
They encompass process safety management chemicals listed under OSHA
Guidelines, Part 1910.119, which require written programs and include
substances such as:
• Ammonia. • Bleach liquors.
• Cadmium. • Chlorine.
• Chlorine dioxide. • Hydrogen peroxide.
• Hydrogen sulfide. • Non-combustible gasses.
• Ozone. • Sodium hydroxide.
• Sulfur dioxide. • Sulfuric acid.
Contractor employees will be aware that only those personnel with specific
training may address certain substances. Some of these are:
• Ionizing radiation.
Related Safety Topics and Practices
Contractor employees will be aware of these safety practices and procedures.
General First Aid for Chemical Exposures - Contractor employees will
know basic first aid procedures needed to respond to chemical exposures
and reporting procedures.
Exposure Control Methods & Procedures - Contractor employees will
know methods and procedures for controlling exposure to hazardous
materials, including appropriate personal protection equipment (PPE).
Basic Chemistry - Contractor employees will understand basic chemistry
terms and concepts (examples: flammable, oxidizer, corrosive) to facilitate
competency in the routine handling of hazardous materials or in
responding to emergencies.
Basic Handling Procedures - Contractor employees will understand
handling procedures for hazardous materials whether exposure is to small
or single-use quantities, or those in large or bulk volumes.
Site specific training is likely to be required to address labels and labeling
Emergency Response Procedures - Contractor employees will know the
appropriate procedures for responding to hazardous materials
Nuclear and Ionizing Devices - Contractor employees will be aware of
the potential hazards associated with naturally occurring radiation and
nuclear and ionizing devices used in paper installations and how to protect
Labels and Other Forms of Warning - Contractor employees will be
aware of requirements that all containers (original containers and those
containing transferred substances) of hazardous chemicals must be
labeled, tagged or marked with the identity of the material and appropriate
hazard warnings. They will be aware that such containers may also
include information on precautionary measures.
Contractor employees will be aware that contractors have a responsibility
to notify paper mills of any hazardous materials they bring into a work site,
including providing a MSDS.
LOCKOUT / TAGOUT
Lockout / tagout programs protect employees from the potential hazards created
by the accidental release of energy.
• Lockout programs – involve physically turning off and locking out energy
flows from a power source to a circuit or device that utilizes the energy.
• Tag-out programs – involve the placement of warning / informational tags
on power sources cautioning against restoring energy flows.
Keys to Lockout / Tagout
• Lockout / tagout general awareness.
• Energy control procedures.
• Shut-down and start-up procedures.
• Paper industry process equipment hazards.
• Group lockout.
• Removal of locks.
Lockout / Tagout General Awareness
Contractor employees will understand lock-out / tag-out programs, including:
• Purpose and objectives.
• Responsibilities of “affected” and “authorized” employees.
• Procedures for controlling energy sources.
• Importance of “verification: try, lock and try.”
Contractor employees will know the difference between “lockout” and “tagout”
procedures and why each is necessary for workplace safety.
Energy Control (Primary, Secondary) Procedures
Contractor employees will be aware of the risk presented by hazardous energy,
• Accidental (intentional, unintentional) start-up.
• Electric shock.
• Unexpected release of stored, residual or potential energy.
Contractor employees will be aware of the types of energy and methods used to
control each, including:
• Chemical • Gravity
• Electrical • Hydraulic
• Mechanical • Pneumatic
• Potential • Steam
• Thermal • Water (under pressure)
Shut Down and Start Up Procedures
Contractor employees will be aware of the steps and procedures used by
authorized employees to shut down and start up equipment or energy sources
controlled by a lock-out program, including:
Preparing a Shut Down – Includes:
• Identification of the type and magnitude of the energy to be controlled.
• Identification of associated hazards of the energy to be controlled.
• Identification of control methods to be used.
Performing a Shut Down – Includes:
• Notification of all affected contractor employees.
• Identification and location of all energy sources.
• Compliance with procedures specific to each energy source.
• Turning off energy, and/or release of stored energy or the attainment of
“zero energy state.”
• Lock out of energy control devices.
• Use of multiple lockout devices if more than one individual will work on
• Attempted restart of the equipment to verify successful lockout.
• Implementation of lockout procedures at shift or personnel changes if
• Continual inspection/monitoring of equipment and lockout status.
Performing a Start Up – Includes:
• An assessment by authorized employees that it is safe to remove
lockout and tagout devices before a start up.
• Testing or inspection by a qualified person that equipment may be
reenergized and that all tools and related electric devices have been
Removal of Locks and Group Lockout – Contractor employees will be
aware that each lock and tag is to be removed by the individual who
applied it or that individual supervises the removal.
Special circumstances are required if the individual who applied the lock
and tag is not available at the time of removal.
Paper Industry Process Equipment Hazards
Contractor employees will be aware of the potential hazards presented by paper
industry process equipment, and that those process equipment hazards also are
addressed in site specific training.
MATERIAL HANDLING, HOISTS, CRANES & RIGGING
Material handling addresses a range of activities, including proper procedures by
individuals performing “hands on” activities and those working with or in the
vicinity of simple (hand truck, wheelbarrow) to complex/sophisticated (forklifts,
cranes) material-handling equipment, hoists and rigging.
Each present unique risks, which are managed through a variety of safety
practices and devices.
Keys to Material Handling, Hoists, Cranes & Rigging
• Hazard awareness.
• Safety practices and procedures.
• Qualified operators for cranes.
Contractor employees will be aware of the potential dangers associated with
material handling – whether with specialized equipment or “by hand” – and the
rules, procedures and devices used to eliminate or control the dangers.
Some equipment common to paper industry construction sites include:
• Deck cranes. • Fork trucks.
• Gantry equipment. • Scissors lifts.
• Tracked cranes. • Wheeled cranes.
Safety Practices and Procedures
Contractor employees will be aware of the following safety practices and
Inspections & Record-Keeping - Contractor employees will be aware of
the essential importance of pre-job and periodic “quick” inspections,
combined with routinely scheduled inspections, plus record-keeping by a
competent person, to assure the safety of material handling equipment
Need for Safe Working Loads & Operations - Contractor employees will
be aware that safety requirements vary depending on the load type and
lifting operation. Individuals will be aware of the role of riggers in assuring
safe material handling operations.
Contractor employees will understand that whenever rigging is used on a
jobsite a competent person must inspect it before the lift is undertaken.
Contractor employees will understand that loads must never be hoisted
over workers and load limits may never be exceeded.
Paper Installations Hazards – Contractor employees will be aware of
hazards specific to paper installations, including paper roll stands, and
safety regulations when working in areas where pulp logs are received,
stored, transported or handled.
Types of Ropes, Lines, Chains, Hooks, Ends & Attachments -
Contractor employees will be aware of safety considerations and
procedures related to the various types of ropes, lines, chains, hooks,
ends and attachments used in material handling operations.
Slings - Contractor employees will be aware of the potential dangers
specific to the use of slings. The use of slings requires the expertise of
riggers and application of the rules relating to rigging.
Dangers and Precautions Around Suspended Loads - Contractor
employees will understand guidelines necessary to assure safe conditions
around and in the vicinity of suspended loads.
Industrial Trucks, Forklifts & Related Equipment - Contractor
employees will be aware of safety procedures utilized when in an area
where industrial trucks, forklifts and similar equipment pass (near or
through) or are operated.
“Hands On” Material Handling - Contractor employees will be aware of
the rules, procedures and equipment needed to assure the safe handling
of materials when performed by hand (lifting, carrying, pushing, pulling).
Examples of “hands on” material handling considerations include:
• Planning the job in advance.
• Use of mechanical devices (e.g., dollies, carts, wagons) whenever
possible and practical.
• Assuring that individuals are capable of the weight they will lift, carry,
push or pull.
• Assuring the individuals are in satisfactory physical condition to handle
the weight they will lift, carry, push or pull.
• Lifting with leg muscles – not with back muscles.
• Starting a lift as close to the load as possible.
• Avoiding turning or twisting when handling materials.
• Clearing a safe path to the destination before handling materials.
• Always seeking help from other workers when necessary.
• Avoiding over-exertion.
• Always erring “on the safe side.”
Material Storage - Contractor employees will be aware of safety
procedures used to safely store materials, including how to stack, pile,
block, interlock or otherwise secure them.
Floor Loading Requirements – Contractor employees will be aware of
the potential hazards from improper floor loads and the need for a
competent person to assure floor loading requirements are followed.
Qualified Operators for Cranes
Contractor employees will understand that only qualified individuals may operate
cranes, and that there are specific, detailed regulations pertaining to the
operation of cranes and related activities.
MOTOR VEHICLES & MOTORIZED EQUIPMENT
Motor vehicles are defined as those that may operate legally at work sites and on
public roads and highways. Motorized equipment includes specialized devices
such as cranes and railroad engines and rolling stock.
Cars, trucks, motorized and railroad equipment add another dimension to
workplace hazards. Quite simply, humans almost always are the losers in
accidents involving this equipment. A range of devices and practices are utilized
to assure safe conditions from common sense – “stop, look and listen” – to
specialized tools. Contractor employees need to be aware of these devices and
Keys to Motor Vehicles & Motorized Equipment
• Motor vehicle awareness.
• Motorized equipment awareness.
• Railroad equipment awareness.
• Forklift traffic.
Motor Vehicle Awareness
Contractor employees will be aware of the potential dangers presented by motor
vehicles and the rules, procedures and equipment used on paper industry
property to eliminate or control the dangers.
Individuals will understand that the level of motor vehicle safety necessary within
the perimeter of pulp and paper industry installations is at least the same as that
required on public highways and streets – and may be more stringent depending
on the specific location, time or circumstance/condition.
Motorized Equipment Awareness
Contractor employees will be aware of safety procedures needed when working
with or in the vicinity of various mechanized vehicles, including:
• Construction equipment. • Fork trucks.
• Earth-moving equipment. • Other material handling equipment.
Railroad Engines & Rolling Stock
Contractor employees will be aware of the safety procedures needed when
working around railroad engines and rolling stock at paper industry installations,
including the use of “blue flag” devices.
Fork Lift Traffic
Contractor employees will be aware that paper installations typically have a
significant amount of fork lift traffic and will understand the need for caution.
PERSONAL PROTECTIVE EQUIPMENT (PPE)
OSHA reports that, on average, 500 workers are injured on-the-job every day.
One simple, but effective protection against a range of common injuries is the
use of personal protective equipment – hardhats, ear and eye protection, gloves,
hard-toed shoes and boots, and specialized devices such as respirators and life-
Contractor employees need to know what PPE tools are available to them, which
are mandatory, and the requirements regarding proper fit, use and maintenance.
Keys to Personal Protective Equipment (PPE)
• PPE assessment.
• PPE awareness and basics.
• PPE equipment and applications.
Contractor workers will be aware that employers are required to assess the
workplace to determine if hazards are, or are likely to be, present, and if PPE is
necessary. If so, employers select the appropriate PPE to be used by workers
and assure that the workers utilize the devices.
Awareness and Basics
Contractor employees will have an awareness of the following aspects of
personal protective equipment (PPE):
• What, when and where PPE is required.
• How to properly select PPE based on the task to be performed or the
• The proper fit, maintenance, inspection, useful life and disposal of PPE.
Minimum awareness of PPE encompasses the equipment and applications
Additionally, other PPE equipment or procedures may be necessitated in
response to special or unique circumstances addressed by local, state, federal,
contractor and / or owner rules.
Hardhats - Contractor employees will be aware that ANSI-approved
hardhat use is mandatory at paper industry installations. Individuals will
further understand the proper use of hardhats, including the function of
their components, including the shell and the suspension.
Eye Protection - Appropriate eye protection is mandatory at paper
industry installations and may include a range of tools, such as:
• ANSI-approved safety glasses with side shields.
• Goggles/face shield.
• Cutting goggles/welding hood (awareness includes understanding filter
lens shade numbers).
• Laser protective devices.
Hearing Protection - Hearing protection awareness includes an
understanding of the types of protection (e.g., disposable and reusable
plugs, muffs or headsets), ratings of protection devices, an understanding
when hearing protection is required, and proper hygiene practices related
to hearing protection equipment.
Hand Protection - Contractor employees will be aware when gloves are
required to assure safe working conditions, the types of gloves to be
utilized depending on the circumstances:
Contractor employees will also be aware of other types of hand protection
that are required or beneficial, depending on task or environment.
Foot Protection - Contractor employees will be aware that ANSI-
approved safety shoes are mandatory at paper industry installations.
Contractor employees also will be aware of the need for adequate foot
protection in general, and the types of protective footwear that may be
required depending on the circumstances.
Clothing - Contractor employees will be aware that clothing requirements
may be included in PPE safety programs, including mandatory
requirements regarding types of pants/leg covering, shirt and other
specialized protective clothing.
Individuals will also be aware that certain activities may necessitate
additional limb and/or torso protective wear.
Other PPE Applications - In addition to general PPE awareness and
competency, contractor employees will be aware that other types of PPE
devices may be required, depending on conditions and activities, such as:
• Life-saving devices.
• Personal flotation devices.
• Safety nets.
POWERED INDUSTRIAL TRUCKS
Powered industrial trucks used to move material at pulp and paper mills are
complex, specialized equipment. Contractor employees will understand that they
must not be operated without advance, specific written permission, and
Contractor employees also will understand the need to be alert to powered
industrial truck traffic in the pulp and paper mill environment.
Keys to Powered Industrial Trucks
• Use of equipment.
• Specialized training.
• Industrial traffic.
Use of Equipment
Contractor employees will understand they are not permitted to use powered
industrial trucks owned by the paper company except under rare conditions.
Such conditions require the advance, written permission of an authorized
representative of the paper company.
Contractor employees will be aware that in the rare condition that approval is
granted to utilize a powered industrial truck, specific training must be provided
prior to the usage.
Contractor employees will receive site-specific information regarding safe
practices in a paper installation that uses powered industrial trucks. Topics will
• Designation of safe walkways and floor markings.
• Designation of safe work area boundaries.
• Signals, horns and alarms used by operators of powered industrial trucks
moving forwards and backwards.
• Awareness of the operator’s “blind spots.”
• Safe conduct around parked and in-use powered industrial trucks.
PROCESS SAFETY MANAGEMENT (PSM)
Process safety management (PSM) embodies rules, regulations and procedures
designed to prevent or minimize the consequences of an accidental release of
toxic, reactive, flammable or explosive chemicals used in pulp and paper
Process means any activity involving hazardous chemicals including using,
storing, manufacturing, handling and/or moving them.
It applies to any of more than 130 toxic and reactive chemicals and to flammable
liquids and gases in quantities of 10,000 pounds or more. Those most common
to paper plants are: chlorine, chlorine dioxide, sulfur dioxide and sulfuric acid.
Contractor employees will understand that the foundation of PSM is process
hazard analysis and application:
• Paper companies performing a comprehensive assessment of risks and
hazards, and identifying safeguards to be implemented to prevent
releases of hazardous chemicals, liquids and gases.
• Contractors assuring their employees are adequately trained in PSM
topics and procedures in order to perform their jobs safely.
It must be emphasized that PSM generally requires advanced or specialized
training, knowledge and skills.
Additionally, PSM requires pre-job planning and preparation, and may
necessitate specific tools or equipment, plus certification or permitting by the host
paper company and/or contractor.
It also must be stressed that an awareness level understanding of process safety
management is not intended to provide the training, knowledge or skills
It is intended to assure that contractor employees know and can recognize
potential hazards, understand that specific regulations and procedures exist, and
never start or become involved in any project affecting process safety
management without the necessary approval(s).
Keys to Process Safety Management
• Process safety information and hazard analysis
• Paper company responsibilities.
• Contractor responsibilities.
Process Safety Information & Hazard Analysis
Contractor employees will be aware that paper companies must conduct a
compilation of written process safety information before initiating a process
The information must include the hazards of the chemical in the process, the
technology of the process, and the process equipment.
Hazard analysis includes the availability of the following information:
• Hazards of the process.
• Engineering and administrative controls applicable to the hazards, including
applicable detection methodologies.
• Consequences of failure of engineering and administrative controls.
• Human factors.
• Qualitative evaluation of a range of possible safety and health effects on
employees in the workplace if there is a failure of controls.
Paper Company Responsibilities
Contractor employees will be aware of paper company PSM responsibilities,
• Inform contractor employers of the known potential fire, explosion or toxic
release hazards related to the contractor’s work and the process.
• Explain to contractor employers the applicable provisions of an emergency
• Develop and implement safe work practices to control the presence, entrance
and exit of contractor employees in covered process areas.
• Evaluate periodically the performance of contractor employers in fulfilling their
obligations (see below).
• Maintain a contractor employee injury and illness log related to the
contractor’s work in the process areas.
Contractor employees will be aware of contractor’s PSM responsibilities,
• Ensure that contractor employees are trained in the work practices necessary
to perform their job safely.
• Ensure that contractor employees are instructed in the known potential for
explosion or toxic release hazards related to their job and the process.
• Ensure that contractor employees are instructed in the applicable provisions
of an emergency action plan.
• Document that each contractor employee has received and understood the
training required by the OSHA standard by preparing a record that contains
the identity of the employee, the date of training, and the means used to verify
that the individual understood the training.
• Ensure that each contractor employee follows the safety rules of the facility,
including the required safe work practices.
• Advise the paper company of any unique hazards presented by the contractor
Respiratory hazards are not always easily detectable. Contractor employees will
be aware of situations which may present a respiratory hazard, the types of
personal protective equipment (PPE) available to address the hazard and related
Keys to Respirators
• Hazard recognition.
• Types of equipment.
• Safety practices.
Contractor employees will understand why, when and where respirators are
necessary and that specific regulations govern their use, including the availability
of a written policy.
Individuals will be aware of the potential risk to their lungs/respiratory system,
including those presented by:
• Chemicals. • Smoke and vapors.
• Gases. • Particulates.
• Sprays. • Oxygen-deficient environments.
Types of equipment.
Contractor employees will be aware of different air-purifying devices and uses,
• Disposable masks.
• Reusable respirators.
• Supplied-air respirators.
Contractor employers will understand the need to follow safety practices,
• Medical evaluations before using a respirator.
• Proper fit for respirators.
• Need for regular inspection and maintenance procedures addressing:
q Holes, cracks, tears, distortion or other damage to equipment.
q Connections that are not tight or cannot be tightened.
q Signs of wear in components including face piece seals, headbands,
valves, connecting tubes, fittings and cartridges.
q Dents or corrosion in filters, cartridges or canisters.
q Maintaining new and standby air or oxygen cylinders at the 90% level.
SCAFFOLDS, LIFTS, LADDERS & STAIRWAYS
Accessing elevated work sites and performing tasks at elevations present a
number of fall hazards. It should be stressed that at elevations the potential for
injury, and the risk of more serious injury, increases dramatically. To assure a
safe work environment at all elevations, contractor employees will be aware of
the potential dangers associated with the use of scaffolds, lifts, ladders and
stairways, and the rules, procedures and equipment used to eliminate or control
Keys to Scaffolds, Aerial Lifts and Personnel Baskets, Manlifts, Ladders &
• Aerial lifts and personnel baskets.
• Ladders and stairways.
Contractor employees will be aware of the types of scaffolds and the unique
hazards of each, including supported scaffolds and suspension scaffolds.
Individuals will understand key topics for each, including:
• Hazards to users.
• Role of guardrails and other fall protection.
• Surface considerations.
• Importance of safe load distribution.
• Assessing the condition of scaffolds.
• Inspection by competent person.
• Erector and user responsibilities.
• Access and egress responsibilities.
• Independent tie-off for suspension scaffolds.
Contractor workers will understand scaffolds must be built only by qualified
erectors and that a competent person must inspect scaffolds before they may be
used. The role of the competent person also includes assuring that scaffolds
remain in a safe condition.
Contractor employees will understand that safe scaffolds must be plumb, level
• Plumb – the scaffolds vertical components are perpendicular to the base.
• Level – the scaffold’s horizontal components are parallel to the base.
• Square – the vertical and horizontal components create 90° right angles at
the point where they interface or connect.
Contractor employees will be aware of safety procedures required when using an
aerial lift or when working in the vicinity where one is in operation. Aerial lifts
typically include aerial ladders, articulating or extensible boom platforms, vertical
towers and combinations of these devices.
Contractor employees will be aware that they are required to wear a body
harness and lanyard attached to the boom or basket of these devices. Load
limits specified by the manufacturer must not be exceeded.
Lifts are to have two sets of controls – the lower set must be capable of
overriding the upper set. Operation of lifts must be by authorized persons only
and a competent person must test the device daily.
Contractor employees will understand that individual facilities may have more
restrictive safety procedures and requirements and that they should receive
appropriate instructions or information.
As with aerial lifts (above), contractor employees will understand the potential
hazards presented by the use of personnel baskets. Prior to a lift all critical
components of the lifting system are to be inspected by the contractor. A
communications system is required between personnel in the basket and
personnel on the ground.
The area in which the lift is to occur must be inspected for overhead hazards
(e.g., electrical lines). A trial lift is required before the actual lift is undertaken.
Fall protection devices must be worn. Individuals must be able to stand on the
floor of the lift basket. They may not sit, perch or climb on the basket’s edge.
They may not use ladders, planks or other devices as a working position.
Contractor employees will understand that individual facilities may have more
restrictive safety procedures and requirements and that they should receive
appropriate instructions or information.
Manlifts are a specific device to move individuals vertically in multi-floor facilities,
including pulp and paper manufacturing installations.
Contractor employees will understand that these are unique devices and should
not be used without advance, site-specific information. Additionally, supervised
use may be mandatory.
Ladders & Stairways
Contractor employees will be aware of safety procedures when using ladders or
• Safety practices necessary when using fixed or portable ladders and
• Proper angles and securement / proper tie-off in ladder safety.
• Weight requirements and limitations.
• Surface considerations.
• Proper height above top landing for ladders.
• Condition of ladders.
• User responsibilities.
• Carrying materials up a ladder.
Individuals will understand that any change in elevation of 19 inches or more
requires a stairway or ladder if no other means is provided. Ladders must extend
at least 3 feet above landings.
Individuals will be aware of the need for proper ladder maintenance and ladder
and stairway housekeeping.
Contractor employees will be aware of the need for training in the safe use and
operation of devices such as freight elevators at paper industry facilities,
including load limits and the dangers of overloading.
SIGNS, SIGNALS & BARRICADES
Contractor employees will be aware of the absolute need to observe and comply
with informational safety signs, signals and barricades in assuring a safe working
Contractor employees will be aware that they will receive site specific information
regarding signs, signals and/or barricades prior to commencing work at a paper
Keys to Signs, Signals & Barricades
• Safety signs.
• Safety signals, alarms and warning lights.
• Traffic and railroad signs.
Contractor employees will be familiar with the meaning and use of various types
of informational safety signs used in pulp and paper installations and on
construction sites at such installations, including:
• Danger and caution signs.
• Safety instruction signs.
• Routine and emergency egress signs.
Safety Signals, Alarms & Warning Lights
Contractor employees will be familiar with the use of various types of
informational signal and warning lights used in pulp and paper installations and
on construction sites.
Contractor employees will be aware that they should receive site specific
training/instructions in the alarms, signals and warning lights unique to the
individual paper industry installation at which they are working.
Contractor employees will be familiar with the use of various types of accident
prevention tags and tape in pulp and paper installations and on construction sites
at such installations to assure safety, including:
• Danger tags & tapes.
• Caution tags & tape.
• Accident prevention tags.
• Informational tags.
Danger signs: alert workers to hazards that are an immediate threat.
Caution signs: warn of potential hazards or are reminders to avoid unsafe
Accident prevention tags are temporary and warn against an existing hazard.
They may include messages such as:
• Out of Order • Do Not Use • Do Not Operate
Traffic and Railroad Signs
Contractor employees will understand the importance of observing traffic and
railroad signs posted in and around pulp and paper installations. Contractor
employees will understand the meaning of railroad “blue flag” devices.
Contractor employees will understand the importance of barricades (including
safety cones and similar devices) used to demarcate safe work areas.
SITE – SPECIFIC SAFETY ORIENTATION
Broad safety programs are effective at addressing potential workplace hazards
and risks. They are essential in preventing accidents, mitigating the affects of
accidents that do occur, assuring effective emergency responses, and minimizing
Nevertheless, paper companies recognize that each of their installations is
different. Site-specific safety orientations are used to communicate safety rules,
regulations and procedures specific to individual companies/sites to assure a
safe workplace for contractor employees and paperworkers.
Contractor employees will know:
1. A safety orientation will be presented prior to commencing work, and
2. The nature or type of information to be provided.
Keys to Site-Specific Safety Orientation
• Why and when site-specific safety orientation are presented.
• Type of information communicated in an orientation session.
Why and When Site-Specific Safety Orientations Are Presented
Uniform safety rules, regulations and procedures are created to reduce or
mitigate common workplace risks and hazards. But, because every workplace is
different, it is imperative for contractor workers to receive site-specific safety
orientations every time they commence a new project at a paper installation.
Orientations are necessary for all contractor employees regardless of previous
experience or level of training. For example, some contractor employees may be
familiar with one or more paper industry facilities – likely because they have
worked there previously.
But, in many instances, they enter an industrial environment in which they are
unfamiliar with pulp and paper manufacturing equipment and processes, the
facility’s physical layout, routine workplace practices and emergency procedures.
Even if once familiar with a facility, contractor employees may return to an
installation where some rules, procedures, conditions, or the physical layout,
Site-specific safety orientations are essential in assuring a safe environment for
contractor employees whether they will be on-site for part of a day or engaged in
a long-term (multi-day, multi-week) project.
Additionally, site-specific safety orientations for contractor employees are
important to assure a safe workplace for papermakers working in the proximity of
or adjacent to contractor projects.
Type of Information Communicated in an Orientation Session
Essential, useful information is presented in site-specific orientation sessions.
While presentations are as varied as the individual companies and their different
facilities and conditions, a list of potential topics that contractor employees may
commonly expect includes:
Emergency Evacuation/Shelter Routes & Procedures
• Exits, evacuation routes, areas for assembly.
• Shelters and routes to them.
• Evacuation/shelter policies and procedures.
Audible (i.e., sirens, bells, horns, PA announcements) and / or visible (i.e.,
illuminated or flashing lights, message boards) devices used by paper
companies to rapidly communicate safety-related information to all on-site
Emergency Equipment and Response
• Availability and location of first aid and medical care and related
• Availability and location of:
q phones and emergency numbers
q fire alarm report systems or boxes
q fire extinguishers
q portable defibrillators
q emergency eyewash and shower facilities
• Access points and in-bound / out-bound routes designated for fire
fighters, hazmat teams, ambulances, EMTs and police.
Permits, Certifications, Written Programs and Operational Policies
Paper company’s rules and policies regarding the need for permits,
certification and / or written programs addressing topics and activities
including, but not limited to:
• Confined space entry • Cranes
• Demolitions • Electrical safety
• Excavations • Eye wash locations
• Fire extinguisher locations • Floor load limits
• Hazard communication • Heavy lifts
• Hot work • Jackhammers
• Line breaking & equipment openings • Lockout/Tagout
• Man lifts & elevators • MSDS compliance
• Mobile equipment • Personal protective equipment
• Personnel / lift baskets • Power lines
• Process safety management • Radiation sources
• Radiography • Scaffolds
• Substance spills & reporting
General Operational Guidance
Addresses information and policies regarding:
• Accident / injury reporting • Bathroom locations
• Borrowing of equipment • Cameras / camcorders
• Code of conduct • Contractor equipment access
• Eating/vending/break areas • IDs (badges, hard hat logos)
• Parking sites, permits & restrictions • Medical & first aid provision
• Restricted areas • Safety-related signage
• Signs, signals & barricades • Smoking restrictions
• Worksite cleanliness/neatness • Worksite waste disposal
General operational guidance presented during the orientation may include
other miscellaneous information and instruction helpful in assuring a safe
workplace for contractor and paper industry employees.
TOOLS – HAND & POWER
The use of common and specialized hand and power tools occurs throughout
construction sites whether at paper industry installations or other locations. It is
easy to forget that all types of tools can cause injuries if they are not properly
used and maintained – from those that are painful and irritating to those that are
disabling and even fatal.
Common hazards include lack of guards on tools and grinders, improper care
around rotating parts, wheels or blades spinning or speeding too fast, and poorly
Contractor employees will be aware of the rules and practices pertaining to hand
and power tools that assure a safe workplace by eliminating or controlling
Keys to Tools – Hand & Power
• Hand tool safety.
• Power tool safety.
Hand Tool Safety
Contractor employees will be aware of these issues assuring hand tool safety.
Improper Use – Contractor employees will be aware that one of the two
most common reasons for accidents with hand tools is their improper use.
Individuals should be aware of the proper procedures needed with all
hand tools they use.
Maintenance – The other most common reason for hand tool accidents is
poor maintenance. Contractor employees will be aware of the need to
properly maintain their hand tools and to routinely and periodically inspect
them to detect signs of wear, deterioration or defects.
Unsafe conditions often include hammers and similar devices with broken,
splintered or defective handles or loose heads, wrenches with sprung
jaws, and chisels with “mushroomed” heads.
Personal Protective Equipment – Contractor employees will be aware of
the personal protective equipment required for the safe use of hand tools.
Power Tool Safety
Contractor employees will be aware of these issues assuring safe use of power
tools, including those that are:
Guarding - Contractor employees will be aware that equipment guards must
be installed and must remain in-place to protect the operator and construction
and paper industry personnel in the vicinity.
Individuals will understand that effective guards are needed in at least three
key points on equipment, including:
• Nip points.
• Point of operation.
• Any point where there is potential for air-borne or spraying particles,
debris or sparks.
Contractor employees will be aware that a variety of machine parts require
• Belts • Chains • Gears
• Fly wheels • Pulleys • Rotating devices
• Shafts • Sprockets • Spindles
Personal Protective Equipment (PPE)
Contractor employees will be aware of the types of personal protective
equipment needed to assure the safe use of various power tools.
Contractor employees will be aware of ON / OFF and other safety switches
and their operation to assure safe working conditions.
Contractor employees will be aware of the unique safety rules and
procedures to assure the safe operation of powder-actuated tools. Use of
powder-actuated tools requires advance, specialized training and instruction.
Contractor employees will be aware of safety rules, ratings and procedures
needed when using or working in the vicinity of various types of grinders,
• Portable. • Air-powered.
• Electric-powered. • Fuel-powered.
• Abrasive wheels • Abrasive tools.
Contractor employees will be aware of the safety rules, ratings and
procedures needed when using or working in the vicinity of saws, including:
• Chain saws. • Concrete saws.
• “Cut off” and special tip saws. • Gasoline-powered saws.
• Hand-fed saws. • Crosscut table saws.
• Ripsaws. • Radial saws.
Contractor employees will be aware of the safety rules and procedures
needed when using or working in the vicinity of mechanical and pneumatic
Workers will understand that safe operating limits for jacks must never be
WALKING & WORKING SURFACES
Accidents relating to walking and working surfaces – often referred to as “slips,
trips and falls” – too frequently are not considered as seriously as other accidents
and potential workplace hazards. Unfortunately, they can result in lost time,
serious injuries and fatalities. OSHA reports that falls cause an average of 8½
work days lost per accident and represent about one-third of all construction
Contractor employees need to be aware of the potential dangers of walking and
working surfaces in pulp and paper installations, and the rules, procedures and
equipment used to eliminate or control the dangers.
Keys to Walking & Working Surfaces
• Basics of slips, trips and falls.
• Wet, humid and moist conditions.
• Seasonal considerations.
• Paper industry specific hazards.
• Work platforms.
• Other cautions and safety practices.
Basics of Slips, Trips & Falls
Contractor employees will understand the role that physical factors play in
causing slips, trips and falls, including:
• Friction • Gravity • Momentum
Wet, Humid & Moist Conditions
Contractor employees will be aware of the potential for wet, humid and moist
conditions on walking and working surfaces in pulp and paper installations.
Contractor employees will be aware of the seasonal need for extra caution and to
apply sand and/or salt to assure safe walking and working surfaces.
If work platforms will be used during the course of work, contractor employees
will be aware of the hazards presented by their use; requirements regarding their
use, size, placement and weight-bearing capabilities; and rules and regulations
designed to mitigate any hazards.
Paper Industry Hazards
Contractor employees will be aware of the potential hazards that pulp and
chemicals pose to safe walking and working surfaces in pulp and paper
Other Cautions and Protective Practices
Contractor employees will be aware of other potential hazards and methods to
address them, including:
Floor Holes & Covers - Contractor employees will be aware of the
potential danger presented by floor holes and the proper use of hole
Housekeeping - Contractor employees will be aware of the need to
practice good housekeeping to maintain safe walking and working
Tripping Hazards - Contractor employees will be aware of the types of
hazards that have potential to cause trips and stumbles, including
temporary and permanent hazardous conditions.
Depressions - Contractor employees will be aware of the potential
dangers presented by depressions in walking and working surfaces.
SAFETY BMPs (BEST MANAGEMENT PRACTICES)
FOR CONTRACTORS, CONTRACTORS’ EMPLOYEES
AND PAPER COMPANIES
Assuring a safe workplace requires paper companies, contractors and
contractors’ employees to participate in a partnership that is dedicated to
These safety BMPs are tools paper companies and contractors can utilize to
help assure safer workplaces. They are grouped in three categories
reflecting general responsibility for implementation:
I. Primarily the responsibility of owners and contractors.
II. Primarily the responsibility of owners.
III. Primarily the responsibility of contractors and their employees.
Contractor Safety BMPs
Pertaining to Owners and Contractors
A. Each owner, general contractor and sub-contractor will designate an on-site
representative (i.e., competent person) specifically responsible for workplace
safety. Close, effective coordination of communications among these
personnel, and with the workers for which they are responsible, is required to
facilitate a safe working environment for all employees.
B. Owners and contractors will generally prohibit the borrowing of equipment by
their employees. Owners will generally prohibit their employees from
borrowing equipment from contractors.
In limited circumstances the non-routine use of paper company equipment by
contractors may be permitted by the owner’s designated representative.
Contractors must indicate in writing that they have inspected the equipment,
determined it is safe for use, and agreed to use it consistent with all
Clarifying Note: For all scheduled project work, contractors are expected to
provide all work and safety equipment needed on-site. Any borrowing by
owner’s’ employees or contractors’ employees is discouraged and should be
a rare, exceptional event. Exceptions include owners’ equipment agreed
upon in advance (pre-project), or after work have begun, if approved in writing
by the owner’s designated representative. This should be limited to
equipment that is essential to project efficiency, deadlines, facilitation of multi-
contractor operations, or which could not reasonably be anticipated in
advance. A potential list of such equipment includes, but is not limited to,
scaffolding, heavy equipment, material handling equipment and overhead
cranes. The list does not include routinely required equipment.
Contractor Safety BMPs
Pertaining Primarily to Paper Companies (Owners)
A. Owners will develop and utilize pre-qualification standards that assess a
contractor’s safety history and current accident avoidance / minimization
programs in order to select those with a demonstrably effective safety
program (e.g.: experience modification rates, incident rates, citation history,
references, contractor’s safety instruction program).
Quantitative data to be requested by owners typically will include information
from the three preceding years that report project hours and incidents on an
The data from all participating members is to be provided to the Wisconsin
Paper Council for compilation as a single report.
B. Owners will require contractors to individually identify, prior to the start of a
project, all employees assigned to the project and certify that each has
received safety awareness instruction and that the certification is current.
Personnel updates are to be provided as necessary over the project’s course.
C. Owners will develop a means to assure accurate identification, on a daily
basis, of all contractor employees arriving at their facilities (e.g.: controlled
access, checkpoints, work period security checks, ID’s, hard hat stickers).
D. Owners will implement a program to assure the integrity of the ID program
(e.g.: cross-referencing ID’s with contractor safety instruction records).
E. Owners will provide site-specific information, such as alarms, warning signals
and related information (e.g., unique safety conditions / circumstances,
evacuation routes and procedures, evacuation gathering-marshalling areas,
shelters) to all contractor employees prior to the start of a project and as
necessary during the project.
Contractor Safety BMPs
Pertaining Primarily to Contractors and
A. Contractors will have a system in-place to investigate and report all injuries.
OSHA-recordable incidents will be reported by the next business day. A
summary of incidents is required at the conclusion of the project.
B. Firearms will not be accessible or removed from secured storage in any
vehicle on paper industry property as consistent with state and local
C. Possession of illegal drugs and the consumption of alcohol on paper industry
property are prohibited.
D. All contractor employees will be aware of ground fault circuit interrupter
(GFCI) use and assured grounding programs, in addition to the proper routing
of electrical cords specific to the job site, and quarterly maintenance-
E. All contractor employees must wear ANSI-approved hardhats. They must
prominently display lettering, symbols and/or colors that provide clear, easy
identification of their employing contractor.
F. All contractor employees must wear ANSI-approved safety glasses with side
Individuals may be required to wear additional, or secondary, eye protection
in designated areas or when performing certain tasks.
G. All contractor employees must wear hearing protection in designated areas.
H. All contractor employees must wear ANSI-approved footwear.
I. Contractors must obtain advance permission to bring any chemicals on-site.
Proper labels must be displayed on all chemical containers.
Material safety data sheets (MSDS) must be available from the contractor.
Contractors and owners may develop a standardized list of routinely used,
pre-approved chemicals; it must be reviewed by the owner prior to the start of
each new project.
PAPER INDUSTRY CONTRACTOR SAFETY
A Assuring that contractor employees are adequately trained in safety rules,
regulations and procedures is the responsibility of contractors in cooperation
with the workforce and related interests.
B The Wisconsin Paper Council will provide, and update as necessary, a
document explaining “awareness level” safety training for contractor
employees. Contractor employees will be expected to demonstrate their
knowledge of safety policies and procedures at an awareness level prior to
commencing work at paper industry facilities and at regular intervals after the
C OSHA and all applicable state and local safety rules, regulations and codes
are the minimum compliance level permissible at paper industry facilities.
D Owners shall develop a reasonable policy of consistent, progressive steps,
including record keeping, which assures compliance with safety rules and
regulations by contractor employees.
E The policy shall include consideration of retraining or supplemental training.
F Enforcement steps shall be consistent with the nature of the violation and the
risk it presents to individual and workplace safety.
PAPER INDUSTRY CONTRACTOR SAFETY
CODE OF CONDUCT
A All contractor employees are required to demonstrate proficiency at the
“awareness level” in safety topics and procedures identified by the paper
industry prior to commencing work at paper industry facilities. Follow-up
proficiency demonstrations are required at regular intervals.
B All contractor personnel are expected to conduct themselves in a professional
and business-like manner on paper industry job sites.
C Inappropriate behavior (including harassment of any kind), horseplay,
practical jokes, and physical threats will not be tolerated.
D All contractor employees are expected to stay within their authorized work
area on paper industry job sites.
E No contractor employees will be allowed to wander onto or go on any other
company property, for any purpose, without the specific permission of the
project supervisor or other authorized personnel on paper industry job sites.